Case 1:22-cv-10904-JSR Document 191 Filed 06/20/23 Page 1 of 7 401 9m St. NW. Suite 630 Washington, DC 20004 o. 202.232.5504 f. 202.232.5513 MotleyRice ATTORNEYS A.! LAIR/ Linda Liam:din DC NY direct: 202.386.9626 [email protected] www.molleyrice.com "I will stand for my client's rights. I am o triol lawyer." -Ron Motley 11944-20131 CONFIDENTIAL. FILED UNDER SEAL June 7. 2023 BY ECF Hon. Jed S. Rakoff United States District Court Southern District of New York Daniel Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 RE: Gov't of the U.S. Virgin Islands v. JPMorgan Chase Bank, N.A., Case No. 1:22cv-10904-JSR (S.D.N.Y.) — Motion Seeking Leave to Reopen Depositions Dear Judge Rakoff: On May 31, 2023, the Court ordered Plaintiffs to submit letter briefs no later than 5:00 PM on June 7, 2023 seeking to recall a witness if they believe "that a document was produced in an untimely fashion, and that they would have confronted a witness at a deposition with that document if it were produced in a more timely fashion." Based on several documents produced late in the discovery period, Plaintiff the Government of the United States Virgin Islands ("USVI") respectfully requests that the Court: I. grant leave to recall Mr. Dimon for one additional hour; and 2. grant leave to reopen the Rule 30(b)(6) deposition on the topic of Epstein client referrals; and 3. grant leave to take the deposition of Howard Maleton; and 4. compel JPMorgan to produce specific categories of documents about Bear Steams employees' knowledge of Epstein's activities and relationship with Bear Stearns until and after it was acquired by JPMorgan in 2008. FAT. PLEASANT. SC I FAORGANTOWN, WV I CHARLESTON. WV I PROVIDENCE. RI I WASHINGTON. DC I CHERRY S PHILADELPHIA. PA I HARTFORD. CT I NEW YORK, NY NJ EFTA02808715